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Home My WebLink About13-3605 Supreme Co' . Pennsylvania Cour Gomon Pleas For Prothonotary Use Only: TIME STAMP C1 it 1 �Ve !et Docket No: CUM County (D The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the Cling and service of leadin s or other papers as required by law or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: C PORTFOLIO RECOVERY ASSOCIATES, LLC AMBER GRIFFITH Ti I Are money damages requested? ® Yes El No Dollar Amount Requested: X within arbitration limits O N (Check one) outside arbitration limits j 1 Is this a Class Action Suit? []Yes ®No Is this an MDJAppeal? ❑ Yes ®No A Name of Plaintiff /Appellant's Attorney: Robert N. Polas, Jr./ Carrie Brown/ Mark R. Garvey ❑ Check here if you have no attorney (are a Self - Represented [Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS • Intentional ❑ Buyer Plaintiff Administrative Agencies • Malicious Prosecution ❑ Board of Assessment • Motor Vehicle ❑ Debt Collection: Credit Card ❑ Board of Elections • Nuisance ® Debt Collection: Other ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability (does not include S mass tort) ❑ Employment Dispute: ❑ Slander/Libel/Defamation Discriminati E ❑Zoning Board C E] Other: [I Employment Dispute: Other ❑ Other: T 1 C] Other: MASS TORT 0 ❑ Asbestos N ❑ Tobacco REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort -DES ❑ Toxic Tort - Implant ❑ Ejectment ❑ Common Law /Statutory Arbitration B C3 Toxic Waste [] Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Other: [3 Ground Rent E] Mandamus ❑ Landlord /Tenant Dispute ❑ Non - Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Partition ❑ Replevin PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: 13 -09613 Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 r F _ Mark R. Garvey, Esquire PA Bar # 312686 " �' P o Ha, Portfolio Recovery Associates, LLC iO TAF� `( 120 Corporate Blvd .I(�' 2 Norfolk VA 23502 4 10' 1J TELE: 1- 866 - 428 -8102 C(. "t3ER jD C() FAX: (757) 518 -0860 PEPNs YLVAt01 JNT y Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 No. I 3b&S I �/ Plaintiff, V. AMBER GRIFFITH 497 HIGHLAND CT CARLISLE PA 17013 Defendant. NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action withing twenty (20) days after this Complaint and Notice are served, by entering a written appearance, personally or by an attorney, and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the Court without further notice of any money claimed or any other claim or relief requested by the Plaintiff. You may lose money or property rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT-AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service - CUMBERLAND County Bar Association Court Administrator 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 Pennsylvania Lawyer Referral Service (800) 692 -7375 13 -09613 �Ul This communication is from a debt collector and is an attempt to collect a debt. a� r1 / S Any information obtained will be used for that purpose. l O' Robert N. Polas, Jr., Esquire PA Bar # 201259 Cairie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1- 866 - 428 -8102 FAX: (757) 518 -0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Demandante, No. V. AMBER GRIFFITH 497 HIGHLAND CT CARLISLE PA 17013 Demandado. NOTICIA USTED HA SIDO DEMANDADO/ A EN LA CORTE. Si usted desea defender conta la demanda puestas en las siguientes paginas, usted tienen que tomar accion dentro veinte (20) dias despues que esta Demanda y Aviso es servido, con entrando por escrito una aparencia personalmente o por un abogado y archivando por escrito con la Corte sus defensas o obejciones a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas aviso por cualquier dinero reclamdo en la Demanda o por cualquier otro reclamo o alivio solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante para usted. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LAMME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEGUIR UN ABOGADO. SI USED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS. QUE PEUDAN OFRECER SERVICIOS LEGAL A PERSONAS ELGIBLE UN HONORARIO REDUCIDO O GRATIS. Lawyer Referral Service - CUMBERLAND County Bar Association Court Administrator 32 South Bedford Street Carlisle, PA 17013 (717) 249 -3166 Pennsylvania Lawyer Referral Service (800) 692 -7375 13 -09613 Esta comunicaeion es de un. cobrador de deudas y es un intent do cobrar ma deuda. C,ualquier infromacion. sera util..izada Para ese propos.ito. Robert N. Polas, Jr., Esquire PA Bar # 201259 Carrie Brown, Esquire PA Bar # 94055 Mark R. Garvey, Esquire PA Bar # 312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1- 866 - 428 -8102 FAX: (757) 518 -0860 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK, VA 23502 Plaintiff, No. V. AMBER GRIFFITH 497 HIGHLAND CT CARLISLE PA 17013 Defendant. COMPLAINT 1. Plaintiff, Portfolio Recovery Associates, LLC is a Delaware. Limited Liability Company with offices located at 120 Corporate Blvd, Norfolk, VA 23502. 2. Defendant, AMBER GRIFFITH, is an adult individual with last known address of 497 HIGHLAND CT, CARLISLE PA 17013. 3. It is averred that Defendant was indebted to GENERAL ELECTRIC CAPITAL CORP / HH GREGG on November 28, 2010 with account number * * * * * * * * * ** *3984 (hereafter referred to as "Account "). A copy of the account history is attached here to and collectively marked as Exhibit " 4. By using the Account, Defendant agreed to repay any incurred balances and/or charges made to the Account pursuant to the terms and conditions governing said Account. Failure to pay Defendant's incurred charges on the Account is considered a default. This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. 5. At all relevant times material hereto, Defendant has used said Account for the purchase of products, goods and/or for obtaining services. 6. Defendant was provided with copies of the Statements of Account showing all debits and credits for transactions on the aforementioned Account to which there was no bonafide objection by Defendant. 7. Defendant was in default with respect to that debt for failure to make the required payments on the Account. The last payment made on this Account was on March 21, 2012. 8. Plaintiff is the purchaser, assignee and/or successor in interest GENERAL ELECTRIC CAPITAL CORP / HH GREGG and Plaintiff is now the holder of the Account. A true and correct copy of the Plaintiffs verification is attached hereto and collectively marked as Exhibit "A." 9. As of the date within Complaint, the remaining balance due, owing and unpaid on Defendant's Account, as a result of Defendant and/or any authorized user's use of said Account is in the sum of $1,784.34. 10. Despite reasonable and repeated demands for payment. Defendant has refused and continues to refuse to pay all sums due and owing on the aforementioned Account, all to the damage and detriment of the Plaintiff. 11. The amount in controversy is within the jurisdictional amount requiring compulsory arbitration. WHEREFORE, Plaintiff respectfully requests this Honorable court enter Judgment in favor of Plaintiff and against Defendant, AMBER GRIFFITH, in the 4 e. $1,784.34, lu costs of this action and any other relief as the Court deems just and reaso Carrie 1k. Brown, Esquire, 94055 Robert N. Polas, Jr., Esquire, # 201259 Mark R. Garvey, Esquire, # 312686 Attorneys for Plaintiff 13 -09613 This communication is from. a debt collector and is an. attempt to collect a debt. Any infom. ation obtained will be used for that purpose. VERIFICATION The undersigned Custodian of Records for Portfolio Recovery Associates, LLC, Nicole J. Mc He�reby states that he /she is authorized to take this verification on behalf of said Plaintiff in the within action and verifies that the statements made in the foregoing Complaint are true and correct to the best of his/her knowledge, information, and belief, based upon information provided by the Plaintiff. The undersigned understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. MAY 21 2013 Date: By: Nicole . oore Custodian of Records 13 -09613 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. X IBIT A This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. ......... ....._.. ___. PORTFOLIO RECOVERY ASSOCIATES, LLC ..� 120 Corporate Blvd r Norfolk, VA 23502 Telephone: 1- 866 - 428 -8102 � Fax: (757) 518 -0860 Statement of Account Account: * * * * * * * * * ** *3984 AMBER GRIFFITH Account Holder: AMBER GRIFFITH 497 HIGHLAND CT CARLISLE PA 17013 Consumer Account Product Code: PVT Issuer: GENERAL ELECTRIC CAPITAL CORP / HH GREGG Assignee: Portfolio Recovery Associates, LLC Account Number: * * * * * * * * * ** *3984 Date Account Opened: November 28, 2010 Date of Last Payment: March 21, 2012 Date of Charge Off- July 29, 2012 Balance at Purchase: $1,784.34 Purchase Date: August 21, 2012 Balance at Charge -Off: $1,784.34 Less Payments: $.00 Balance Due: $1,784.34 13 -09613 GESP75 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. AFFIDAVIT State of Virginia City of Norfolk ss. Nicole J. Moore I, the undersigned, , Custodian of Records, for Portfolio Recovery Associates, LLC hereby depose, affirm and state as follows: 1. I am competent to testify to the matters contained herein. 2. 1 am an authorized employee of Portfolio Recovery Associates, LLC, ( "Account Assignee ") which is doing business at Riverside Commerce Center, 120 Corporate Blvd, Norfolk, VA 23502. 1 am familiar with the policies and practices, as well as the books and records of Account Assignee with respect to the matters stated herein. This affidavit is based upon my personal knowledge of Account Assignee's record keeping system and my review of Account Assignee's records, including a review of the business records transferred to Account Assignee from GENERAL ELECTRIC CAPITAL CORP / HH GREGG ( "Account Seller "), which have become a part of and have integrated into Account Assignee's business records, in the ordinary course of business. 3. According to the business records, which are maintained in the ordinary course of business, the account, and all proceeds of the account are now owned by the Account Assignee, all of the Account Seller's interest in such account having been sold, assigned and transferred by the Account Seller on August 21, 2012. Further, the Account Assignee has been assigned all of the Account Seller's power and authority to do and perform all acts necessary for the settlement, satisfaction, compromise, collection or adjustment of said account, and the Account Seller has retained no further interest in said account or the proceeds thereof, for any purpose whatsoever. 4. According to the records transferred to the Account Assignee from Account Seller, and maintained in the ordinary course of business by the Account Assignee, there was due and payable from AMBER GRIFFITH ( "Debtor ") to the Account Seller the sum of $1,784.34 with the respect to account number ending in * * * * * * * * * ** *3984, as of July 29, 2012 with there being no known un- credited payments, counterclaims or offsets against the said debt as of the date of the sale. 5. According to the records of said Account Assignee, after all known payments, counterclaims, and/or setoffs occurring subsequent to the date of sale, Account Assignee claims the sum of $1,784.34 as due and owing as of the date of this affidavit. 6. Plaintiff believes that the defendant is not a minor or an incompetent individual, and declares that the Defendant is not on active military service of the United States. P folio Recov ry Associat ,LLC Nicole J. Moore . By: stodian of Records Sur1hedand sworn to before me on M 212013 , 2013 WI/ — Notary Public Tavana C. Uzzle q, Commonwealth of Virginia 13 -09613 Notary Public Commission No. 302460 My Commission Expires 113112017 E This com.inunication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Request for Service Ronny R. Anderson, Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx:717.240.6397 Plaintiff /s: Court Number: PORTFOLIO RECOVERY Expiration Date: ASSOCIATES, LLC Type of Action: CIVIL Defendant /s: AMBER GRIFFITH Serve Upon: AMBER GRIFFITH r Address for Service: 497 HIGHLAND CT CARLISLE PA 17013 Alternate Address for for Service: Type of Service: ❑ Adult in Charge ❑ Personal ❑ Deputize ❑ Certified Mail ❑ Posting Copy of Court Order Required with Posting' Special Service Instructions: *If service is to be made by deputized service to another county please specify which county* Filing Attorney: Name: Robert N. Polas, Jr. Address: 120 Corporate Blvd Norfolk, VA 23502 Phone Number: 1- 866 - 428 -8102 13 -09613 GESP75 Um GE .Capital BILL of SALE PRA PSCC Fresh — August 2012 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement"), dated as of the 25`' day of June, 2012 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery Associates, LLC ( "Buyer"), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on August 21, 2012, and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services, L.L.C. By: By: ' 7 - Glenn Marino Glenn Marino Title: _EVP Title: _President Date: Date: General Electric Capital Corporation RFS Holding, L.L.0 By �' B Glenn Marino Joseph Ressa Title: _Vice President Title: CFO Date: GEMB Lending, Inc. GEM Holding, L.L.0 By: By: Stephen Motta Joseph Ressa Title: _General Manager Title: _CFO Date: Date: GE Capita! BILL of SALE PRA PSCC Fresh — August 2012 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement "), dated as of the 25 day of June, 2012 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and OEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on August 21, 2012, and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services, L.L.C. By: B y . Glenn Marino Glenn Marino Title: _EVP Title: President Date: Date: General Electric Capital Corporation i�,FS Holding, L.L.0 By: By: Glenn Marino Joseph Ressa Titre: — Vice President Title: CFO Date: Date: GEMB Lending, Inc. GEM Holding, L.L.0 By: �-- By: Stephen Motta Joseph Ressa Title: _General Manager _ Title: _CFO _ Date: �IIZ Date: GE Capita! BILL of SALE PRA PSCC Fresh — August 2012 For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Receivables Purchase Agreement (the "Agreement "), dated as of the 25` day of June, 2012 by and between General Electric Capital Corporation, GE Money Bank, GEMB Lending, Inc., Monogram Credit Services, L.L.C., RFS Holding, L.L.C., and GEM Holding, L.L.C. (collectively "Seller ") and Portfolio Recovery Associates, LLC ( "Buyer "), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Receivables as set forth in the Notification Files (as defined in the Agreement), delivered by Seller to Buyer on August 21, 2012, and as further described in the Agreement. GE Capital Retail Bank Monogram Credit Services, L.L.C. By: B Glenn Marino Glenn Marino Title: _EVP Title: President Date: _ Date: General Electric Capital Corporation RFS Holding, L.L.0 By: B , Glenn Marino Joseph sa Title: _Vice President_ Title: — CFO Date: T Date: GEMB Lending, Inc. GEM Holding, L.L.0 By: S!cphen Motta Joseph Re Title: _General Manager Title: CFO Date: Date: SHERIFF'S OFFICE OF CUMBERLAND COUNTY C-) , Ronny R Anderson -Z r"co Sheri ff �t'�;arura,��. � Jody S Smith Chief Deputy ! �� `��co CD Richard W Stewart "' "' T3 C-) =- — Solicitor OFFCE OF ' _ ' " c.z �� Portfolio Recovery Associates, LLC Case Number vs. 2013-3605 Amber Griffith SHERIFF'S RETURN OF SERVICE 06/24/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Amber Griffith, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not Found" at 497 Highland Court, Carlisle Borough, Carlisle, PA 17013. Deputies were advised by a neighbor that the defendant moved out approximately one month ago. The Carlisle Postmaster states that mail is still delivered to the address provided. SHERIFF COST: $40.24 SO ANSWERS, June 28, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuito Sheriff,Teleosoft,Inc. Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID#940551201259/312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 W13 AUG 20 Ail 7 Attorneys for Plaintiff �'uf�r,'P F,Q I I !J PDRISYLVAtil IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION - LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK,VA 23502 Plaintiff No. 13-3605 CIVIL V. AMBER GRIFFITH 497 HIGHLAND CT CARLISLE PA 17013 Defendant PRAECIPE TO DISCONTINUE To the Prothonotary: Please mark the above-entitled case as discontinued without prejudice. R spe I e?#Submit e Robert N. Polas, Jr., t-squire PA Bar#201259 Carrie Brown, Esquire PA Bar#94055 Mark R. Garvey, Esquire PA Bar#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: (757) 518-0860 Attorneys for Plaintiff 13-09613 This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose. Carrie A. Brown, Esquire Robert N. Polas Jr, Esquire Mark R. Garvey, Esquire Attorney ID#94055/2012591312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PA CIVIL ACTION -LAW PORTFOLIO RECOVERY ASSOCIATES, LLC 120 CORPORATE BLVD NORFOLK,VA 23502 Plaintiff No. 13-3605 CIVIL V. AMBER GRIFFITH 497 HIGHLAND CT CARLISLE PA 17013 Defendant CERTIFICATE OF SERVICE The undersigned does hereby certify that I served a copy of the foregoing Praec'p continue upon AMBBR GRIFFITH,by First Class Mail, Postage Pre-Paid, a copy thereof on this:r ay of 2(V, to: AMBER GRIFFITH, 497 HIGHLAND CT, CARLISLE PA I 13-09613 Robert N. Polas, Jr., esquire PA Bar#20125-9 Carrie Brown, Esquire PA Bar#94055 Mark R. Garvey, Esquire PA Bar#312686 Portfolio Recovery Associates, LLC 120 Corporate Blvd Norfolk, VA 23502 TELE: 1-866-428-8102 FAX: (757) 518-0860 Attorneys for Plaintiff This communication is from a debt collector and is an attempt to collect a debt. Any information obtained will be used for that purpose,